2017 College of Medicine Compliance & Privacy R 2017 College of Medicine Compliance & Privacy R. Brett Short, Chief Corporate Compliance Officer - 859-323-9817  Richard Chapman, Chief Privacy Officer - 859-323-1184

Code of Conduct 4 component policies A01-030 Conflicts of Interest A01-105 Industry Representatives A01-155 UKHC Members Interactions with Industry Representatives A01-160 Annual Disclosure of Financial Conflicts of Interest

Compliance is Everyone’s Responsibility Unethical Illegal Fraud Waste Abuse

Gifts & Vendor Interaction Industry Representatives on Campus No gifts allowed policy Must register with Purchasing or Pharmacy and wear badge By appointment only Not in patient care areas *See policies A01-105 and A01-155

Meal Acceptance Example Meals Meals received for free from industry representatives or vendors are considered gifts and may not be accepted. Exception: Meals can be accepted only when they are offered to all participants as part of an accredited continuing education event. Meal Acceptance Example Lunch provided during APA conference (i.e., Accredited) and all attendees invited Industry sponsored dinner after conference, or invited to dinner by industry colleague OK Not OK *See policies A01-105 and A01-155

Stark Law and Anti-Kickback Statute Related but not the same Stark Law – prohibits physicians from referring Medicare patients to an entity with which the physician or an immediate family member has a financial relationship Anti-Kickback Statute – prohibits receiving inducements in exchange for referrals Contact the Office of Corporate Compliance with questions at 323- 8002

HIPAA Privacy

Protected Health Information (PHI) Individually identifiable information plus health information Held or Transmitted In any form or medium, whether electronic, paper or oral 

Access of Medical Records UKHC staff will see patients that are well known in the community during their time at UK Staff should not use medical records other than for treatment or educational purposes UKHC Privacy will investigate any reported privacy violations

This is a Privacy Breach

Is this a Privacy Breach?

Reporting Talk to your team lead Call the Office of Corporate Compliance: 859-323-8002 Report online ukhealthcare.uky.edu/compliance Call the UK Comply-Line 877-898-6072 See Policy # A06-100 for Reporting